Trivial List

Unless otherwise required by the Director, permits shall not be required for the following source activities. Trivial activities may be presumptively omitted from reporting in part 70 permit applications. However, this trivial listing may not be used to avoid any “applicable requirement” (i.e., NSPS, NESHAP, etc.) as defined in 40 CFR Part 70.2.

Mobile Sources

  1. Combustion emissions from propulsion of mobile sources, except for vessel emissions from Outer Continental Shelf sources.
  2. Fugitive emissions related to movement of vehicles, provided the emissions are not required to be counted for applicability purposes and any required fugitive dust control plan or its equivalent is submitted.
  3. Fugitives from application of sand or salt in the winter months, where the sand or salt is used for vehicle or pedestrian safety

Combustion Equipment

  1. Internal combustion engines used for landscaping purposes.
  2. Emergency (back-up) electrical generators at residential locations.
  3. Portable electrical generators that can be moved by hand from one location to another.
  4. Temporary power generators or boilers used to replace main power generators or boilers during periods of repair or maintenance (provided the temporary sources do not exceed main sources emission limits).
  5. Air Curtain destructors used for land clearing at construction sites.
  6. Crematories of any size.
  7. Boiler water treatment operations, including non-contact water cooling towers.
  8. Smelt viewing ports

Trade Operations

  1. Funeral home activities.
  2. Blacksmith forges.

Agricultural Operations

  1. Herbicide and pesticide mixing and application activities for on-site use.

Maintenance, Cleaning & Housekeeping

  1. Janitorial services and consumer use of janitorial products.
  2. Plant maintenance and upkeep activities (e.g., grounds-keeping, general repairs, cleaning, painting, welding, plumbing, re-tarring roofs, installing insulation, and paving parking lots) provided these activities are not conducted as part of a manufacturing process, are not related to the source’s primary business activity, and not otherwise triggering a permit modification.
  3. Repair or maintenance shop activities (e.g., vehicle repair shops, brazing, soldering, carpenter shops, electrical charging stations, grinding and polishing) not related to the source’s primary business activity, not including emissions from surface coating or de-greasing (solvent metal cleaning) activities, and not otherwise triggering a permit modification.
  4. Steam cleaning and/or steam sterilization operations.
  5. Miscellaneous activities such as aerosol spray cans provided these activities are not conducted as part of a manufacturing process, are not related to the source’s primary business activity, and not otherwise triggering a permit modification.
  6. Cold storage refrigeration equipment.
  7. Vacuum cleaning systems used exclusively for industrial, commercial or residential housekeeping purposes.
  8. Equipment used for the washing or drying of fabricated products provided that no VOCs are emitted in the process and that no oil or solid fuels are burned.

Laboratories and Testing

  1. Bench-scale laboratory equipment used for physical or chemical analysis, but not lab fume hoods or vents.
  2. Routine calibration and maintenance of laboratory equipment or other analytical instruments.
  3. Equipment used for quality control/assurance or inspection purposes, including sampling equipment used to withdraw materials for analysis.
  4. Hydraulic and hydrostatic testing equipment.
  5. Sampling connections used exclusively to withdraw materials for testing and analysis, including air contaminant detectors and vent lines.
  6. Vacuum producing devices.

Pollution Control

  1. Vents from continuous emission monitors and other analyzers.
  2. Garbage handling equipment.
  3. Sanitary wastewater collection systems.
  4. Sanitary wastewater treatment systems, except incineration equipment and municipal treatment facilities.

Industrial Operations

  1. Hand-held equipment for buffing, polishing, cutting, drilling, sawing, grinding, turning or machining.
  2. Brazing, soldering and welding equipment, and cutting torches related to manufacturing and construction activities that do not result in emission of metal HAPs.
  3. Air compressors and pneumatically operated equipment, including hand tools.
  4. Batteries and battery charging stations, except at battery manufacturing facilities.
  5. Equipment used exclusively for rolling, forging, pressing, stamping or spinning metals such as drop hammers or hydraulic presses for forging or metalworking.
  6. Hand-held applicator equipment for hot melt adhesives with no VOC in the adhesive formulation.
  7. Equipment used for surface coating, painting, dipping or spraying operations, except those that will emit VOC(s) or HAP(s).
  8. CO lasers, used only on metals and other materials which do not emit HAP(s) in the process.
  9. Electric or steam-heated drying ovens and autoclaves, but not the emissions from the articles or substances being processed in the ovens or autoclaves or the boilers delivering the steam.
  10. Salt baths using non-volatile salts that do not result in emissions of any regulated air pollutants.
  11. Laser trimmers using dust collection to prevent fugitive emissions.
  12. Coolant emissions from general machining operations.
  13. Hot melt adhesive application with no VOCs in the adhesive formulation.
  14. Industrial equipment and/or processes used exclusively for educational purposes in educational institutions

Heating, Venting and Air Conditioning Operations

  1. Air-conditioning units used for human comfort that do not have applicable requirements under Title VI of the Act.
  2. Ventilating units used for human comfort that do not exhaust air pollutants into the ambient air from any manufacturing/industrial or commercial process.
  3. Bathroom/toilet vent emissions.

Non-commercial Office Operations

  1. Laundry activities, except for dry-cleaning and steam boilers.
  2. Tobacco smoking rooms and areas.
  3. First aid or on-site medical services (does not apply to medical hospitals or commercial medical facilities).
  4. Consumer use of paper trimmers/binders.
  5. Use of space heaters.
  6. Consumer use of office equipment and products (i.e. photocopiers, telefax, desktop printers,etc.), not including printing presses or businesses primarily involved in photographic reproduction.

Storage Tanks and Equipment

  1. Storage tanks, vessels, and containers holding or storing substances that will not emit any VOC or HAP.
  2. Demineralized water tanks and demineralizer vents.
  3. Pressurized storage of oxygen, nitrogen, carbon dioxide, or inert gases.
  4. Liquid/Gas Processing and Handling
  5. Process water filtration systems and demineralizers.
  6. Oxygen scavenging (de-aeration) of water.
  7. Ozone generators.
  8. Steam leaks, steam traps, steam vents and/or steam safety relief valves.
  9. Natural gas pressure regulator vents, excluding venting at oil and gas production facilities.

Food and Cosmetic, Storage and Processing Equipment

  1. Storage tanks, reservoirs, and pumping and handling equipment of any size containing soaps, vegetable oil, grease, animal fat, and non-volatile aqueous salt solutions, provided appropriate lids and covers are utilized.
  2. Non-commercial food preparation or equipment used for cooking food for immediate human consumption.
  3. Equipment used to mix and package: soaps, vegetable oil, grease, animal fat and non-volatile aqueous salt solutions provided appropriate lids and covers are utilized.
  4. Equipment used exclusively to slaughter animals, but not including other equipment at slaughterhouses such as rendering cookers, boilers, heating plants, incinerators, and electrical power generating equipment.


  1. Environmental, shock or humidity chambers not using HAP gases.
  2. Solar simulators.
  3. Fire suppression systems.
  4. Emergency road flares.